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+% discussion 1000
+% - common issues in EIA      400
+% - evaluating NZ's approach  600
+
+\section{Discussion}
+TODO
+
+\subsection{Common deficiencies of EIA implementations}
+
+\subsubsection{Inherent limitations of EIA}
+\parencite{beattie}:
+ - EIA is not science
+   - cannot be science because it makes predictions based on very limited data
+   - may not be advertised as science because it would not stand up to scrutiny
+ - based on value assumptions and inherently biased
+ - EIAs are always political because they are part of a decision-making process
+ - EIAs are necessary because they add valuable information to public
+   discussions on specific proposals
+
+\subsubsection{Other deficiencies}
+
+- limited opportunity for the public to influence decisions
+- poor communication
+- one-off projects / lack of monitoring and follow-up \parencite{follow-up}
+- failure to predict important impacts
+- poor environmental models / baseline => precautionary principle
+
+The following is from \textcite{RMIT University \& UNU Online Learning. (n.d). Environmental
+Impact Assessment Open Educational Resource.}:
+
+- screening is political because it depends on the values of those who perform the screening
+- although political in nature, there is little opportunity throughout
+the process of EIA for the public to be involved; where involvement is possible it is often limited due to lack of resources (time and expertise)
+
+\subsection{Evaluating New Zealand's approach}
+
+``Social Assessment'' (Taylor et al in the Green Book, chapter 25)
+\begin{quote}
+   The New Zealand Resource Management Act (1991) is regarded by many as the
+   foremost and most innovative national legislation for environmental assessment in recent
+   years. This act has included mandatory requirements for the assessment of environmental
+   effects, with “social,” “cultural,” and “amenity values” clearly included in the definition
+   of environment. Also required are public involvement and community consultation, and
+   monitoring of effects once the plan or project has begun.
+\end{quote}
+
+
+checklist from \textcite{intl-perspective}:
+
+- opportunities for public involvement?
+  - only 6\% of resource consents were notified in some way, meaning that the vast majority were granted without involving the public \parencite{rma-survey}
+
+- insufficient monitoring (68\%) \parencite{rma-survey}
+\textcite{retrospect}:
+``EIA generally continues to bring about only relatively modest adjustments of development proposals.''
+  also seems to apply for NZ resource consents:
+  - only a little more than half a percent of all resource consents are declined \parencite{rma-survey}
+
+- problems of devolution:
+  - cannot deal well with cumulative effects, because that's best done on a national/regional level \parencite{eia-state-of-the-art}
+  - most resource consents are processed at the district/city level, not at the regional level
+
+\textcite{practitioners}
+- volume of assessment work, enormous breadth in scale of covered projects
+- those producing an impact assessment are not necessarily skilled in AEE
+- EIA education is secondary concern for pracitioners (one day courses on AEE)
+- strong professional ``imprint'' on the AEE process, no common language
+- no strong central guidance on impact assessment practise --- what is considered adequate is not defined
+- according to survey of practitioners checklists are most often used, matrices and expert EIA systems are not; checklists are overly simplistic.
+- Fourth Schedule of the RMA was most often cited as an issues checklist for assessment
+- assessments are not seen as enabling affected parties to get involved in decision-making --- although this is one of the core principles of EIA
+- results: AEEs are primarily done to fulfill the requirements of the Fourth Schedule, not concerned with meeting international EIA standards/best practise.